Removing Barriers Blog

CUNA Seeks Clarification from NCUA on MLA Rule
Posted September 16, 2016 by CUNA Advocacy

Today we sent a letter to NCUA seeking clarification on a number of issues related to the Department of Defense’s Military Lending Act regulation and recently released guidance. We're asking NCUA to answer ongoing questions related to: purchase money loans, ancillary products, statutory liens, the definition of “vehicle,” and the possibility of a safe harbor. 

This letter follows a letter we sent to DoD in late August urging a minimum six-month delay of the October 3 effective date of the MLA regulation. In the absence of a delayed effective date, that letter sought a safe harbor of at least six months for lenders that are working to comply with the rule but are unable to do so by October 3. 

In the coming days, our regulatory staff will be meeting with NCUA to address these and other continuing concerns with the MLA rule.